\n ~)\l'\ North Carolina Department of Environment and Natural Resources .::,. ~ :

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1 \n ~)\l'\ North Carolina Department of Environment and Natural Resources Pat McCrory Gpvernor October 21,2014 '. John E. Skvaria, Ill Secretary Mr; PatrickBarton President Hitachi Metals North Carolina, Ltd. 1 Hitachi Metals Drive China Grove, NC ::,. ~ : Subject: Air Permit No R07 'Hitachi Metals North Carolina, Ltd. China Grove, Rowan County, North Carolina. Permit Class: Small Facility JD# Dear Mr. Barton: fu accordance with your completed application received October 9, 2014, we are forwarding herewith Permit No R07 to Hitachi Metals North Carolina, Ltd., China Grove, Rowan County, North Carolina for the construction and operation of air emissions sources or air cleaning devices and appurtenances. Additionally, any emissions activities determined from your air permit application as meeting the exemption requirements contained in 15A NCAC 2Q.0102 have been listed for infonnatiori purposes as an "ATTACHMENT" to the enclosed air permit. Please note the records retention requirements are contained in General Condition 2 of the General Conditions and Limitations. If any parts, requirements, or limitations contained in this permit are unacceptable to you, you have the right to request a formal adjudicatory hearing within 3 0 days following receipt of this permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of the entire permit. This hearing request must be in the form of a written petition, conforming to G.S. 150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, l c--~~~n.c_ A._The_form_for_requesting.a.formaLadjudicatory hearing-may-beobtained--upon-request-from.-- the Office of Administrative Hearings. Unless a request for a hearing is made pursuant to G.S. 150B-23, this air permit shall be final and binding. You may request modification of your air permit through informal means pursuant to G.S. 150B-22. This request must be submitted in writing to the Director and must identify the specific provisions or issues for which the modification is sought. Please note that the permit will become final and binding regardless of a request for informal modification unless a request for a hearing is also made under G.S. 150B:-23. Unless exempted by a condition of this permitor the regulaticms, construction of new air pollution sources or air cleaning devices, or modifications to the sources or air cleaning devices described in this permit must be covered under a permit issued by the Division of Air Quality prior to construction. Failure to do so is a violation of G.S and may subject the Permittee to civil or criminal penalties as described in G.S A and B. Mooresville Regional Office - Division of Air Quality 610 East Center Avenue, Suite 301, Mooresville, North Carolina Phone: J FAX: Internet: An Equal Opportunity I Affirmative Action Employer- Made in part by recycled paper

2 Patrick Barton October 21, 2014 Page2 /,, This permit shall be effective from October 21, 2014 until September 30,2022, is nontransferable to future_ owners and operators, and shall be subject to the conditions and limitations as specified therein. Changes have been made to the permit stipulations. The Permittee is responsible for carefully reading the entire permit and evaluating the requirements of each permit stipulation. The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth in this permit~ Noncompliance"With any permit condition is grounds for enforcement action, for-permit. termination, revocation and reissuance, or modification, or for denial of a permit renewal application. Should you have any questions concerning this matter, please contact TonishaDawson at704-::663.~1699. Sincerely,, 5)\{t~ [.~ ~~- Ronald E. Slack, Regional Supervisor Division of Air Quality, NCDENR TAD. Enclosures... c:. Mooresville Regional Office.. -. G:\AQ\SHARED\WPDATA\COUNTIES\IWWAN\0,0117\R07_FERMIT.DOCX,..

3 NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF AIR QUALITY AIR PERMIT NO R07 Issue Date: Octob_er 21,"2014 E~piration Date: September 30, 2022 ' :.. - Effective Date: October 21; 2014 Replaces Permit: 06911R :;... To construct and operate air emission source(s) and/or air cleaning device(s), and for the discharge of the associated air contaminants into the atmosphere in accordance with the provisions of Article 21B of Chapter 143, General Statutes.ofNorth Carolina (NCGS) as amended, and other applicaple Laws, Rules and Regulations, Hitachi Metals North Carolina, Ltd.. 1 Hitachi Metals Drive. China Grove, Rowan County, North Carolina Permit Class: Small Facility ID# (thepermittee) ishereby ~uthorized to construct and operate the air emissions sources and/or air cleaning devices rind appurtenances described below: r==::::::=::::=.--=-= -::;---r= -=-= =-=-=-- -=-=--=-=-= =--=-=-=---= =-=-=--il Emission Emission Source.. 1 Control Control System. SourceiD ----~ ~~~-~~!P~~ J... ~Y~~-~}~ ~--~~-~!:!!!.!~~ natural gas-flred rotary calciner kiln (11.9 impingement plate scruqber (minimum 1. million Btu per hour maximum heat input I of35,45 gallons per minute liquid I t-----~--~~~-r&i-~... rate~prdc e ss m-g--'ferrl:cc'-ox1de-:-a.ml-st:rontium~j- RKWS r. ~ection rafe witli magnesium liyilioxicle]'~-~ ~-- ~a::;;~;;;j:~-~= J -~ ~-- :~~:~:~------~ natural gas-flred rotary calciner kiln (U.9 million Btu per hour maximum heat input ~ rate processing ferric oxide and strontium RKWS carbonate;6,000 pouj.lds per hour ~--:...J tpax~~j~~2~!ss r~t_~ ~ J impingement plate scrubber (minimum of35-45 gallons per mitj.ute liquid injection rate wit4 m~gne~ium hydroxide additive). in accordanpe wit~.the cqmpletedapplication A re~eivedoctober 9, 2014 including any pl~s~ specifications~, previdu~ applications, and other supporting data, all of which are filed with the Department of Environment and Natural Resources, Division of Air Quality (DAQ) and are inporporated.as. part of this permit. Thi~ permit is subject to the fol~owing specified co11d~tions and limitations including any TESTING, REPORTING, OR MONITORING REQUIREMENTS:

4 Permit No R07 Page2 A. SPECIFIC CONDITIONS AND LIMITATIONS 1. Any air emission sources or control devices authorized to construct and operate above must be operated and maintained in accordanqe with the provisions contained herein. The Permittee shall comply with applicable Environmental Management Commission Regulations, including Title 15A North Carolilla Administrative Code (NCAC), Subchapter 2D.0202, 2D.0515, 2D.0516;1D.0521, 2D.0535, 2D.0540, 2D.0611, , 2Q and 2Q ;..: ~ -'.. 2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT- The Permittee, at least 90 days prior to the expiration date of this permit, shall request permit renewal by letter in accordance with 15A NCAC 2Q.0304(d) and (f). Pursuant to 15A NCAC2Q.0203(i), no permit application fee is required for renewal of an existing air permit (without a modification request). The renewal request (with AA appiication form) should be. submitted to the Regional Supervisor; DAQ. Also, at least 90 days prior to the expiration. date. of this peilnit, the Pel111ittee shall submit the air pollution emission inventory report (with Certification Sheet) inaccoidarice withlsancac 2D'.0202, pursuant to N.C. General Statute The report shall be submitted tothe Regional Super'Visor,DAQ and shall document air pollutants emitted for the 2021 calendar year. '. I 3. PARTICULATE CONTROLREQUIREMENT- As required by15a NCAC 2D.0515 "Particulates from Miscellaneous Iridustrial Processes," particulate matter emissions from the emission sources shall not exceed allowable emission rates. The allowable emission rates are, as defined in 15A NCAC 2D.0515,a function of the process weight rate and shall be determined bythe following equation(s), where Pis the process throughput rate in tons per hour (tons!hr) and E is the allowable emission rate inpotmds per hour (lbs/hr). E = 4.10 * (P) 0 67 E = 55 * (P) o.u ~ 40 for P <= 30 tons!hr, or for P >30tons/hr 4.. SULFuR DIOXIDE GbNTROL REQUIREMENT~ As required by 15A NCAC 2D.0516 ".Sulfur Dioxide Emissions from Combustion Sotitces, II sulfur dioxide emissions frqm the combustion sources shall not exceed 2.3 pounds per million Btu heat input. 5. VISIBLE EMISSIONS CONTROL REQUIREMENT- As. required by 15A NCAC 2D.052l"Control ofvisible Emissions," visible emissions from the emission sources,... manufactured after July 1, 1971, shall not be more than20 percent opacity when averaged over a six-minute period, except that six-minute periods averaging not more than 87 percent opacity may occur not more than once in any-hour nor more than four times in any 24-hour.. period. However, sources which must comply with 15A NCAC 2D New Source Performance. Standards'' or.1110 "National Emission Standards for Hazardous Air Pollutants" must comply with applicable visible emissions requirements contained therein: ' 6. NOTIFICATION REQUIREMENT- As required by 15ANCAC 2D.0535, the Permittee of a source of excess emissions that last for more than four hours and tlj.at results from a malfunction, abreakdownofpi'ocess or control equipment or any other abnormal' conditions, shall:...

5 ' Permit No R07 Page3 a. Notify the Director or his designee of any such occurrence by 9:00a.m. Eastern time of the Division's next business day of becoming aware of the occtirrence and describe: 1. the name and location of the facility, :..:.;.,;...,..,., ii. the nature and cause. of the malfunctioo or breakdown, the time when the malfunction or br~akdown is flrst observed, IV. the expected duration,. and. v. an estimated rate of emissions. b. Notify the Director or his designee immediately when the corrective measur~s have been aqcomplished. This reporting requirement does not allow the opetation of the facility in excess of Environmental Management Commission Regulations FUGITIVE DUST CONTROL REQUIREMENT- As required by 15A NCAC 2D.0540 "Particulates from Fugitive Dust Emission Sources,"the Peimitteeshall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissionsbeyond the property boundary. If substantive complaints or excessive fugitive dust emissions from the facility are observed beyond the property boundaries for six minutes in any one hour (using Reference Method 22 in 40 CFR, Appendix A), the owner or operator may be required to submit a fugitive dust plan as described :in 2D.0540(f). "Fugitive dust emissions" means particulate matter that does not pass through a process stack or vent and that is generated within plant property boundaries from activities such as: unloading and loading areas, process areas stockpiles, stock pile working, plant parking lots,.. a.nd plant roads (including access road~ and haul roads) ~ SCRUBBER REQUIREMENTS- As required by 15A NCAC 2D.0611, emissions shall be controlled as described in the permitted equipment list... a. Inspection and Maint~nance Requirements., To comply with the provisions of this permit and ensure that emissions do notexceed the regulatory limits, the Permittee shall perform periodic inspections and maintenance (I&M) as recommended by the manufactmer~ ln addition, the Permi~ee shall perform an annu~l (for each 12 month period following the initial inspection) internal illspection of each scrubber system. As a minimum, the I&M program and each annual inspection should include the following: 1. inspection of spray nozzles, packing material, chemical feed system (if so equipped), and the cleaning/calibration of all associated instrumentation annually.

6 Permit No R07 Page4 b. Monitoring Requirements - The Permittee shall ensure the proper performance of each scrubber by monitoring the following operational parameters: 1. The Permittee shall record the recycle liquid flowrate (range:::::35-45 gallons. per minute) monthly;., c. Recordkeeping Requirements --The results of all inspections and any varhmce from manufacturer's recommendations or from those given in this permit (when!:tpplicable) shall be investigated with corrections made and dates of actions recorded in a logbook. Records of all maintenance activities shall be recorded in the logbook. The logbook (in written or electronic format) shall be kept on-site and made available to DAQ personnel upori request. 9. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING.REQUIREMENT- Pursl1antto 15ANCAC 2b.1100 "Control of Toxic Air Pollutants," and. in accordance with the approved application for an air toxic compliance demonstration, the foljowing permit litnits shall not be exceeded: u -~--.. ~ IL ~~:!~Ll -. -~~ A_i' ~~~~~ j ---~~~ ll_~~~j IIE'J~:~Qity W!_d~ JI~ _dr~~-e~. ~':lri~~--~yc!!:~c~<?-~.!~-~?.i~2 (7_~~!.~2-~:0) J j1 :g_~.:e~un~~-e~e ~o_ur. j.. a Restrictions - To ensure compliance with the above limits, the following restrictions shall apply: i. At no time shall the total chlorine content of the ferric oxide feed stock entering the calciner kilns (ID No. RK1 and RK2) exceed 0.1 percentby weight. ii. Supplier records demonstrating the chlorine content of the ferric oxide feed stock shall be maintained on site and made available to DAQ.personnel upon.. reques. 10. Federal and State Rules Applicable to SourcesExempted from Air Permitting Requirements -Your facility is subject to the following federal and state rules:.. 4p_CFJ{ ~3 ~ NESHAP/MACT -- Subpart ZZZ~ --Reciprocating Internal j. Combusti9E ~~~in~~ _ , which are applicable to some of the emission sources at your facility listed on the "Insigniflca.J;lt/Exempt Activities" list attached to this permit. The purpose of this permit c 0 ndition is to inform. you of your compliance obligations to these applicable rules as they. are enforceable.

7 Permit No R07 Page5 11. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT- Pursuant to 15ANCAC 2Q.0711 "Emission Rates Requiring a Permit, 11 for each of the below liste~ toxic air pollutants (TAPs), the Permittee has made a demonstration that facility-wide actual emissions, where all emission release points are unobstructed and vertically oriented, do not exceed the Toxic Permit Emission Rates (TPERs) listed in 15A NCAC 2Q.071l(b). The facility shall be operated and maintained in such a manner that emissions of any listed TAPs from the facility~ int:iu:ding fugitive emissions,_will not exceed-tpers listed in 15ANeAC. 2Q ;0711(b). a. A permit to emit any of the below listed TAPs shall be required for this facility if actual emissions from all sources will become greater than the corresponding TPERs. b. PRIOR to exceeding any of these listed TPERs, the Permittee shall be responsible for obtaining a permit to emit TAPs and for demonstrating compliance with the requirements of 15A NCAC2D.1100 "Control of Toxic Air Pollutants". c. In accordance with the approved application, the Permittee shall maintain records of operational information demonstrating that the TAP emissions do not exceed the TPERs as listed below:! ~~~~~~~. ~. B~GENERitl.JCONDITIONS-AND LIMITA.TIONS~~- 1. fu accordance with G.S (c)(l), TWO COPIES OF ALL DOCUMENTS, REPORTS. TEST DATA, MONITORING DATA, NOTIFICATIONS, REQUESTS FOR RENEWAL, AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall be submitted to the: Regional Supervisor. North Carolina Division of Air Quality Mooresville Regional. Office 610 East Center Avenue, Suite 301 Mooresville, NC For identification purposes; each submittal should include the facility name as listed on the permit, the facility identification number, and the permit number.

8 Permit No R07 Page6 2. RECORDS RETENTION REQUIREMENT- In accordance with 15A NCAC 2D.0605, any records required by the conditions of this permit shall be kept on site and m:ade available to DAQ personnel for inspection upon: request. These records shall be maintained in a form suitable and readily available for expeditious inspection and review. These records must be kept on site for a minimum of 2 years, unless another time period is otherwise specified.. -.'..-, ANNuAL FEE PAYMENT- Purstiant to.l5a NCAC 2Q.0203(a), the Permittee shall pay the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a timely manner will cause the DAQ to initiate action to revoke the permit. -:,... ") - ' 4. EQUIPMENT RELOCATION- In accordance with 15A NCAC 2Q.0301, a new air permit shall be obtained by the Permittee prior to establishing, building, erecting, using, or operating the emission sources or air cle.aning equipment at a site or location not specified in this permit. 5. REPORTING REQUIREMENT- In accordance with 15A NCAC 2Q.0309, any of the following that would result in previously unpermitted, new, or increased emissions must be reported to the Region~! Supervisor, DAQ:. a. changes in the information submitted in the application regarding facility emissions; b. changes that modify equipment or processes of existing permitted facilities; or C; changes in the quantity or quality of materials processed. If appropriate, modifications to the perniit may then be made by the DAQ to reflect any necessary changes in the permit conditions. In rio case are any new or increased emissions allowed that will cause a violation of the emission limitations specified herein. 6. In accordance with 15A NCAC 2Q.0309, this permit is subject to revocation or modification by the DAQ upon a determination that information contained in the application ~o~r presented in the support thereof is incorrect, conditions under which this permit was granted have changed, or violations of conditions contained in this permifliave occurrea~:rn--~~ accordance with G.S (c)(l), the facility shall be properly operated and maintained at all times in a manner that will effect an overall redl,lction in air pollution. Unless otherwise specified by this permit, no emission source may be operated without the concurrent operation of its associated afr cleaning device( s) and appurten,ances. 7. In accordance with G.S (c)(l), this permit is nontransferable by the Permittee. Future owners and operators must obtain a new air permit from the DAQ. 8. In accordance with G.S (c)(l), this issuance of this permit in no way absolves the Permittee of liability for any potential civil penalties which may be assessed for violations of State law which have occurred prior to the effective date of this permit. 9. In accordance with G.S. 143~ (c)(l), this permit does not relieve the Permittee of the responsibility of complying with all applicable requirements of any Federal, State, or Local water quality or land quality control authority,

9 ' Permit No R07 Page7 10. In accordance with 15A NCAC 2D.0605, reports on the operation and maintenance of the facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such intervals and in such form and detail as may be required by the DAQ. Information required in such reports may include, but isnot limited to, process weight rates, firing rates, hours of opet:ation, and preventive maintenance schedules. -.;."'' 11. A violation of any term or condition of this permit shalhubject the Permittee to enforcement pursuant to G.S A, ] 14B, and C, including assessment of civil and/or criminal penalties. 12. Pursuant to North Carolina General Statute (a)(2), no person shall refuse entry or access to any authorized representative of the DAQ who requests entry or access for purposes of inspection, and who presents appropriate credentials, nor shall any person obstruct, hamper, or interfere with any such representative while in the process of carrying out his official duties. Refusal of entry or access may constitute grounds for permit revocation and assessment of civil penalties. 13. In accordance with G.S (c)(1), this permit does notrelieve the. Permittee of the responsibility of complying with any applicable Federal, State, orlocal requirements governing the handling, disposal, or incineration of hazardous, solid, or medical wastes, including the Resource Conservation and Recovery Act (RCRA) administered by the Division of Waste Management. 14. PERMIT RETENTION REQUIREMENT- In accordance with 15A NCAC 2Q.0110, the Permittee shall retain a current copy of the air permit at the site. The Permittee must make available to personnel ofthe DAQ, upon request, the current copy of the air permit for the site. 15. CLEAN AIR ACT SECTION112(r) REQUIREMENTS- Pursuant to 15A NCAC 2D.2100 i'risk Management Program," if the Permittee is required to develop and register a risk management plari. pursuant to Section 112(r) of the Federal Clean Air Act; then the Permittee is required to register this plan with the USEP A in accordance with 40 CFR Part t ~6~8_. 16. PREVENTION OF ACCIDENTAL RELEASES- GENERAL DUTY- Pursuant to Title I Part A Section 112(r)(1) of the Clean Air Act "Hazardous Air Pollutants- Prevention of Accidental Releases- Purpose and General Duty," although a risk management plan may not be required, if the Permittee produces, processes, handles, or stores any amount of a listed hazardous substance, the Permittee has a general duty to take such steps as are necessary to prevent the accidental release of such substance and to minimize the consequences of any release. This condition is federally-enforceable only.

10 Permit No R07 Page GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS- If emissions testing is required by this perrriit, or the DAQ, or if the Permittee submits emissions testing to the DAQ in support of a permit application or to demonstrate compliance, the Permittee shall perform such testing in accordance with 15A NCAC 2D.2600 and follow all DAQ procedures including protocol approval, regional notification, report submittal, and test results approval. Penilit issued this the 21st of October, 2014~ NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION ~k&)f~ RegionalSupervisor.,.. By Authority of the Environmental Management Co:mmission Air Permit No R07

11 ATTACHMENT to Permit No R07, October 21,2014 Insignificant/ Exempt Activities 1. Because an activity is exempted from being required to have a permit or permit modification does not mean that the activity is exempted from an applicable requirement or that the owner or operator of the source is exempted from demonstrating compliance with any applicable requirement~ When applicable~ emissions from stationary source activities identified above shall be included in determining compliance with the permit requirements for toxic air pollutants under 15A NCAC 2D.1100 "Control of Toxic Air Pollutants" or 2Q.0711 "Emission Rates Requiring a Permit."

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